Firstly, you’re correct that the disparity between the spectrum holdings shown in Vector’s graph (which you published) and the numbers that MBIE previously provided is because Vector’s graph includes a lot of spectrum that is not used for cellular services.

Vodafone owns rights to spectrum in several bands that are not used for cellular services.

For clarity, the spectrum bands currently used for cellular in New Zealand are:

Soon, the 700 MHz band will also be used for cellular. All three operators will own rights in this band.

The 2.5/2.6 GHz band can be used for cellular (equipment is available internationally) but is not currently being used for cellular services in New Zealand. This band is particularly good for high population density areas such as Singapore and Hong Kong, not so good in low density places like New Zealand. In New Zealand no-one has implemented yet. These rights return to the Crown in 2016 (at the latest) if implementation doesn’t occur.

Secondly, while you are correct that the government would not prevent Vodafone (or any other network operator) from using any of its management rights for cellular services, in practice all New Zealand mobile networks are limited by international standards.

This is because cellular handsets are sourced from the international market. It is unlikely that major handset manufacturers would be interested in manufacturing bespoke handsets just for New Zealand given our small size. Therefore the holdings at 2.0, 2.2 and 3.4 GHz are not practical for cellular services.

Finally, there is not yet any international consensus on what frequencies 5G cellular services will use. While it seems likely that ‘5G’ will eventually be standardised at the international level, there is not yet any agreement on what exactly what 5G will be (apart from general statements like 5G will be faster and/or more efficient than 4G). Most of Vodafone’s unused holdings expire at various times over the next 5-8 years. It should not be assumed that Vodafone will automatically be allowed to renew those holdings. The government routinely reviews spectrum holdings five years before expiry and decides whether to make a renewal offer. For example, the government recently reviewed Vodafone’s LMDS holdings and decided not to offer renewal so those rights will return to the Crown in 2018.

In summary, while there may be room for debate about exactly what should be counted, it is not correct to assume that current total UHF spectrum holdings provide a guide to future capacity of an operator to provide cellular services.